Gulf Oil Corp. v. Commissioner
United States Tax Court
Petitioner acquired undivided interests in oil and gas leases located in the Gulf of Mexico before and during the taxable years at issue. Delay rentals were paid within each of the taxable years at issue. These payments allowed Gulf to drill, explore, and produce minerals from any portion of the lease.
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Petitioner acquired undivided interests in oil and gas leases located in the Gulf of Mexico before and during the taxable years at issue. Delay rentals were paid within each of the taxable years at issue. These payments allowed Gulf to drill, explore, and produce minerals from any portion of the lease. Petitioner claimed "abandonments and extraordinary retirements" as to the leases in the Gulf of Mexico on its Federal tax returns for the taxable years 1974 and 1975 in the respective amounts of $ 35,651,455 and $ 108,108,366. The properties allegedly abandoned consisted of potential mineral…
1Opinion of the Court
Goffe, Judge:
The Commissioner determined deficiencies in petitioner’s Federal income tax for the taxable year 1974 in the amount of $80,813,428 and for the taxable year 1975 in the amount of $166,316,320. Petitioner and respondent, by motion granted on November 10, 1983, agreed that certain issues would be severed and tried at a special trial session, which was held at Dallas, Texas.
One of the group of issues tried was designated by the parties as “Worthless Properties.” The issues included are: (1) Whether certain of Gulf’s interests in offshore leases were abandoned in the taxable years at…
2Cases cited22 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Swift & Co. v. Hocking Valley Railway Co.Supreme Court of the United States · 1917
- Brountas v. CommissionerUnited States Tax Court · 1979
- Paul P. Brountas v. Commissioner of Internal Revenue, Paul P. And Lynn T. Brountas v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1982
17 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Gulf Oil Corporation, in No. 89-2049 v. Commissioner of Internal Revenue. Commissioner of Internal Revenue, in No. 89-2050 v. Gulf Oil CorporationCourt of Appeals for the Third Circuit · 1990
- Gulf Oil Corp. v. CommissionerUnited States Tax Court · 1987
- Shell Oil Co. v. CommissionerUnited States Tax Court · 1987
- Gulf Oil Corp. v. CommissionerUnited States Tax Court · 1986
- Gulf Oil Corp. v. CommissionerUnited States Tax Court · 1986
13 more not listed; retrieve them via the Exa API.